Comments on Final Draft Moreton Bay Catchment
Waterways Management Plan
October 1 1998
Firstly let me take the opportunity to congratulate you and your staff on a much improved WMP.
We still have a number of concerns, itemised below, about the WMP and some of its wording.
2.4 Defining Responsibilities for Co-ordination
Since the EP act binds the crown ,the departments other than DEH also have responsibilities for the environmental impacts of their activities. This section also fails to note that DEH has responsibility for auditing these activities and any delegated or devolved responsibilities.
In the Introduction the section entitled 2.4.1 fails to clarify in general what the role of the BRMG is. While previous sections have outlined BRMG's role it still needs to be restated in this section. While the work done by the MBBRWWS is of relevance to the WMP its doesn't consider the totality of the WMP. In that respect the State Departments and BRMG in particular are vital to the inter government co-ordination and the legislative and regulatory arrangements required. As such we view the MBBRWWS as dealing with a subset of the WMP not a substitute for the BRMG process.
This whole section on management models fails to mention regulatory arrangements and legislative reform.
3.2.1 This section fails to identify any outcomes for the catchment and just mentions the Bay and the Waterways. We would, at least, like to see outcomes on the health of water producing areas and aquifer recharge areas.
3.2.4. Achieving the outcomes
WQ1.19 should an "A" priority because the possible impacts of pathogens and other contaminants on the receiving waters and reuse options. Other contaminants such as iron, copper and hormone like chemicals should also be addressed.
WQ1.21 and WQ 1.22 While we support water reuse options we should proceed with caution and prioritise research on identifying other contaminants, not just nutrients, in the waste waters . We do not endorse or support the pumping of waste water into groundwaters. To expose these hitherto reliable water bodies to contaminants is not a reversible action and we should employ the "precautionary principle".
WQ 1.25 If its not "viable" do we just give up ? Polluter pays is an essential element of the EP Act and should be implemented in a lawful way ( ie avoiding being considered an excise) as soon as possible. The load based licensing is an essential part of driving waste minimisation. The trick will be to charge enough but not too much to achieve this.
WQ4.5 this should be an "A" and the DPI should also be a responsible Agent for this outcome. Erosion has been an acknowledged problem for decades and we would hope that somewhere in the Government some one has already been working on this problem.
WQ4.8 and WQ4.9 negotiation and consultation with native title owners and groups is a legal responsibility and should be "A" or at least "B".
WQ5.2-5.3 What does viable mean ? If its not viable do we just give up and go home. There are both moral and legal imperatives that do not allow nature to be just given up on.
WQ6.1 The Port also needs to address the impacts of its extensions on the Moreton bay water circulation . The State Government and the Port must do an full Environmental Impact Study on the Gateway Ports (6000 ha ) land development project.
WQ6.7 in addition to an EMP we need the State Government to apply clear upper limits to navigational dredging based on a fulsome and public assessment of the environmental impacts of this activity.
3.3 Livelihood and resources
1 Should read "Safe, secure and sustainable water supply continues to be provided"
4. Should change "environmental flow requirements" to "environmental requirements"
5 Should read "A sustainable and secure sand and gravel resource established in appropriate locations" we also believe that not just sand and gravel should be identified in that, what we want is a secure and sustainable supplies of concrete based building materials, this could include recycled concrete and alternative concrete additives.
This Section at present fails to make links to the water quality and catchment health impacts of forestry operations.
3.3.4 Achieving the outcomes
LR1.1 the link should be explicit to LR1.4 viz if ambient water quality of rivers and waterways feeding the dams and impoundment are poor so will be the water quality in the dam. It is much better to focus on improving the water quality before its get to the dam or impoundment. With respect to blue green algae problems we know that reducing sediments and nutrients coming in the dam is a one of the best ways to control this problem. SEQWB must institute monitoring of sediment and nutrient inflows. This is not to say the dams and impoundments don't cause a degradation of water quality in their own right.
LR1.3 Again if its not viable do we continue to let the country run down and hope to control an ever increasing problem downstream ? The scale and types of land degradation has been well understood for many decades. We recommend the establishment of a Catchment Protection Bond to finance these repair activities. This should be an "A" priority for DEH( Water EPP ) DPI (Soil Conservation) DNR( Water Resources Act) and SEQWB( Public Liability ).
LR2.1 This should not be left entirely to local governments. There is a state interest via the Protection of Good Agricultural Lands SPP. The DCILGP and DNR/DPI must also play a lead role in this. The RFGM in looking at its regional landscape strategy, can also help address the protection of agricultural landscapes.
LR3.x Assess impacts of climate change on flood risks.
LR3.x Review the assessments of flash flooding potential's in urbanising catchments. Monitor and report on trends in concentration times for sub catchments( this can also be a catchment health indicator).
LR3.x Minimise urban developments on flood plains.
LR4.x Establish payment or credit mechanisms for lands contributing clean baseflow to the waterway ( water production and rewarding good land managers ).
LR4.x Identify sustainable water yields, both for surface waters and ground waters, on a sub catchment basis to feed into WAMP process.
LR5.2 should add "identify and implement"
LR6.x Assess and implement demand reduction strategies to the level of sustainable yields, in rural and urban areas.
LR7.1 The DME cannot be trusted to adequately address the environmental impacts, on water quality, water supply and biodiversity of such activities. The DEH and DNR both have to key agencies in this process because of their legislative responsibilities. Failure to address the environmental impacts of these activities could expose the regulatory bodies to civil cases involving a failure to exercise a statutory duty.
LR8.1 This project is totally opposed in it present form. A full environmental impact study is required as the Gateway Ports study failed to address vegetation impacts, water pollution, noise pollution, air pollution, flooding impacts and acid sulfate impacts. the destruction of Pinkenba village by turning it into a road interchange is totally opposed.
3.5.1 Liveability and lifestyles - Outcomes
While we support improved access to the riparian corridors it should be noted we do not want to see this "maximised". The riparian corridors have important ecological roles that can be damaged by human access. The more access there is the more these impacts will have to be managed and policed. We oppose the multiple (ab)use of all riparian corridors, bikeways, boating facilities, recreational facilities and pathways will all have a negative effect on habitat values. These negative effects can include noise, physical damage, litter, fires, water pollution, weeds and domestic animals to name just a few.
We need a strategy LL2.x Assess environmental impacts both individually and cumulative and set carrying capacities for each use and total use.
LL10.1 We refer again to our comments about viability. If its not viable who is going to do something about policing and when ?
3.6 Coordinated Waterways management
CW1.3 This should be an "A" priority given the departments responsibilities under the Water EPP and the IPA. BCC already has a waterways program and while its not fully integrated yet it is improving environmental management and hopefully delivering better advice on development applications.
This Section also needs to have scope introduced to investigate whole of water cycle planning and financing options for programs.